July 2024 – Page 3 – European Sanctions Enforcement

July 1, 2024July 10, 2024 by Mark Handley

Germany – raids and arrests for suspected exports of luxury cars to Russia in breach of sanctions

On Friday the Customs office in Frankfurt raided and searched 24 residential and business premises mostly in Offenbach am Main and Aschaffenburg although Customs said the network extended across Germany. Four individuals were arrested. The actions were part of an investigation into the suspected export of luxury cars to Russia in breach of EU sanctions.

The individuals arrested were aged between 39 and 44 with one woman and three men.

The allegation is that 170 luxury cars had been exported since 2022.

Five cars were seized as part of the raids along with evidence and €300,000 in cash. In addition a freezing order was obtained over €13.3m in bank accounts said to be the profits from the enterprise.

The German authorities have been particularly active in enforcement related to luxury cars of late:

July 1, 2024July 12, 2024 by Mark Handley

Poland – sanctions enforcement statistics including 20 fines to date

As part of the press article (behind a paywall) on the recent fines against Novatek Green Energy and Geleo (see our post here), the Polish authorities have also provided an update on their enforcement activity more broadly.

- - Total administrative proceedings commenced: 48
  - Final decisions to date: 33
  - Declination or waiver of fine or finding of no breach: 13
  - Fines imposed to date: 20
  - Ongoing proceedings: 15
  - Total fines to date: 4.8m zloty (c. $1.2m)

Certainly the figure for total fines does not include the fine against Novatek Green Energy (which was 12 million zloty), but it is also a little unclear whether or not the figure includes the fine against Geleo (which was 4m zloty).

The report also notes that most of the 20 penalties have been imposed in 2024, with only two imposed by the end of 2023 for a combined total of 71,000 zloty (c. $17,700).

These enforcement actions appear to relate to a mix of EU and the separate Polish sanctions.

No information has been provided as to the conduct which gave rise to the fines, or who the fines were imposed on.

July 1, 2024July 1, 2024 by Mark Handley

Poland – fines imposed on two companies for circumvention of Russian sanctions

Now updated from the post first published on 28 June.

It is being reported (behind a paywall) that the Malopolska Customs and Tax Office of Krakow has imposed fines of 12 million zloty (c. €2.78m) against Novatek Green Energy and 4 million zloty (c. €927,000) against employee-owned company Geleo.

The fine against Geleo was imposed on 31 May. It was for breach of the relevant asset freeze and for circumvention of Polish sanctions. The transaction in question was the purchase, for €1, of 100% of the shares in Novatek Green Energy from the Swiss company Novatek Gas and Power GmbH, which in turn is a direct subsidiary of the Russian company OAO Novatek.

The fine against Novatek Green Energy was imposed on 25 June, and was imposed for multiple transactions in breach of the imposed asset freeze.

With particular thanks to Dr Marcin Łukowski who provided a copy of the relevant article.